Modern Slavery Statement

California Transparency in Supply Chains Act of 2010 and the United Kingdom Modern Slavery Act of 2015 Statement

The California Transparency in Supply Chains Act of 2010 and the United Kingdom Modern Slavery Act 2015 (the “MSA“) each requires certain businesses to publish an annual statement specifying the efforts taken to prevent slavery and human trafficking in their business or supply chain. Otter Products, LLC, and its affiliates and subsidiaries, including, but not limited to, Otter Products EMEA Unlimited and Otter Products UK Limited (collectively, “Otter Products“) is opposed to slavery and human trafficking in any part of its activities and supply chains, and is therefore committed to ensuring that we have adequate policies and procedures in place to identify and prevent these practices.

Organization’s Structure

Our organization is part of a global group of companies in the consumer electronics sector that manufacture and distribute (amongst other things) accessories for mobile devices.

Our Policies on Slavery and Human Trafficking

We are committed to working against modern slavery and human trafficking in our supply chains and in our business. As part of this effort, Otter Products has adopted the Responsible Business Alliance Code of Conduct (the “RBA Code of Conduct“). The RBA Code of Conduct requires, among other things, that its direct suppliers ensure they do not engage in or support modern slavery or human trafficking. In addition, the RBA Code of Conduct requires suppliers to adopt and maintain terms of employment for their employees that comply with local law and requirements of decency.

Due Diligence Processes for Slavery and Human Trafficking

Our efforts to manage our supply chain relationships responsibly include the following actions:

1. Verification of Product Supply Chains. Otter Products strives to establish close relationships with its suppliers and requires that they comply with all aspects of the RBA Code of Conduct including those aspects that relate to modern slavery and/or human trafficking.

2. Supplier Audits. Otter Products reserves the right to verify supplier compliance with company standards and the RBA Code of Conduct. Otter Products utilizes independent third party auditors to perform announced supplier audits and verify supplier compliance. If Otter Products becomes aware of any actions or conditions not in compliance with its company standards and/or the RBA Code of Conduct, Otter Products reserves the right to demand corrective measures which may include terminating the supplier’s contract.

3. Certification Requirements for Direct Suppliers. Otter Products requires its direct suppliers to certify that materials incorporated into the products comply with the laws regarding modern slavery and human trafficking of the country or countries in which they are doing business. Otter Products presents the RBA Code of Conduct as a total supply chain initiative and requires suppliers to comply with laws regarding forced labor and human trafficking. Otter Products also requires suppliers to monitor the performance of their next tier suppliers against the requirements of the RBA Supplier Code of Conduct.

   As part of the requirements of the RBA Code of Conduct and specialized labor standards, suppliers are required to develop appropriate management systems, which include policies, procedures and associated documentation, to adhere to the requirements and any applicable laws and regulations, including those prohibiting modern slavery and human trafficking. We confirm the existence and maintenance of those management systems through our supplier audit program.

4. Internal Accountability Standards and Procedures. Otter Products requires its employees to comply with company policies, including, but not limited to, policies prohibiting the use of modern slavery and human trafficking in its operations. Otter Products provides channels to report concerns about any potential violation of law or company policy including those related to modern slavery or human trafficking. Otter Products promptly investigates any such reports and takes all necessary corrective actions.

5. Training. Individuals who have direct responsibility for supply chain management have access to trainings, information on all company policies, practices, and procedures designed to identify and respond to issues related to forced labor and human trafficking in the supply chain as well as to mitigate risks with the supply chain of products.

Further Steps

Otter Products recognizes that identifying and mitigating the risks of modern slavery and human trafficking requires on-going commitment and continual improvement. We will therefore continue to develop and implement the measures identified above in respect of our supply chain.

This statement is made and reflects the position of Otter Products as of November 1, 2021.